SOC 2 vs PCI DSS: Differences for Fintech Companies
SOC 2 and PCI DSS both apply to fintech software. Understand the difference, which applies to you, and how to pursue both efficiently.
- PCI DSS is mandatory for any company that stores, processes, or transmits cardholder data; SOC 2 is voluntary.
- PCI DSS v4.0 has 12 high-level requirements and 250+ specific controls; SOC 2 is more flexible in scope.
- Fintech companies that use Stripe or Braintree and never touch raw card data may be out of PCI DSS scope — verify with a QSA.
- SOC 2 Security criterion and PCI DSS overlap significantly: access control, encryption, logging, and vulnerability management.
- Indian fintech companies also face RBI guidelines on data localisation that interact with both frameworks.
In this guide
Overview
Fintech companies are frequently asked about both PCI DSS and SOC 2. Customers want to know their payment data is safe (PCI DSS) and that the company's overall security posture is audited (SOC 2). These are related but distinct requirements with different governing bodies and different consequences for non-compliance.
What Is PCI DSS?
The Payment Card Industry Data Security Standard (PCI DSS) is a set of security requirements created by the PCI Security Standards Council — a body founded by Visa, Mastercard, American Express, Discover, and JCB. PCI DSS v4.0, released in March 2022, is now the current mandatory standard.
PCI DSS applies to any organisation that stores, processes, or transmits cardholder data (credit or debit card numbers, CVVs, PINs, magnetic stripe data). Compliance is enforced by payment card brands through your acquiring bank — non-compliance can result in fines, increased transaction fees, or termination of merchant agreements.
Validation options range from Self-Assessment Questionnaires (SAQs) for smaller merchants to a full Report on Compliance (ROC) assessed by a Qualified Security Assessor (QSA) for larger merchants and service providers.
Key Differences
Mandatory vs voluntary: PCI DSS is contractually required by payment card brands for any entity handling cardholder data. SOC 2 is voluntary, driven by customer and market demand.
Scope: PCI DSS scope is defined by cardholder data flow. If you use a payment processor like Stripe or Razorpay in a way that means cardholder data never touches your systems, you may be out of scope for most PCI DSS requirements. SOC 2 scope is defined by your service commitments.
Specificity: PCI DSS v4.0 has 12 requirements broken into ~250 specific controls with very prescriptive technical requirements. SOC 2 is principles-based — auditors assess whether your controls meet the criteria, but specific implementations are not mandated.
The Scope Question for Fintech
Many fintech startups believe they are in PCI DSS scope when they are not — or vice versa. The key question is: does raw cardholder data (primary account number, CVV, magnetic stripe data) ever enter your systems?
If you use Stripe Elements, Razorpay's hosted payment page, or a similar tokenised payment solution correctly, cardholder data is captured directly by the payment processor and never passes through your servers. You may qualify for SAQ A (the simplest self-assessment questionnaire) with minimal requirements.
If you store card numbers (even encrypted), process raw PANs, or run your own payment gateway, you are in full PCI DSS scope and likely need a QSA assessment. Engage a PCI QSA early to determine your actual scope before investing in controls.
Control Overlap
PCI DSS Requirements 7 (access control), 8 (authentication), 10 (logging and monitoring), and 11 (security testing) map closely to SOC 2 CC6.1–CC6.8 (logical and physical access) and CC7 (system operations and monitoring). Building these controls for SOC 2 provides a strong head-start for PCI DSS.
PCI DSS-specific requirements with no direct SOC 2 equivalent: cardholder data environment segmentation (network scoping), physical cardholder data protections, payment application security, and the specific cryptographic requirements for card data (PCI PTS).
Indian Fintech Considerations
Indian fintech companies must also consider RBI's guidelines on payment data localisation (circular dated 6 April 2018), which requires all payment data related to Indian customers to be stored exclusively in India. This interacts with PCI DSS cloud hosting requirements.
The DPDP Act 2023 adds a further layer for personal data processing. Indian fintech companies handling customer financial data should map their DPDP obligations alongside any PCI DSS and SOC 2 programmes.
For Indian fintech companies selling to US enterprise customers: SOC 2 is typically the primary requirement. PCI DSS may not apply if you are not directly handling cardholder data — clarify your actual PCI scope before investing in full QSA engagement.
Which Do You Need?
You need PCI DSS if your system stores, processes, or transmits cardholder data. There is no choice — it is required by your acquiring bank and payment card brand agreements. Start by scoping your cardholder data environment with a QSA.
You need SOC 2 if enterprise customers request it — which is increasingly the case for fintech SaaS, even without direct cardholder data handling. SOC 2 addresses broader security posture beyond just payment data.
Most fintech companies growing toward enterprise sales will eventually need both. Build SOC 2 first (more structured path, cleaner auditor market), then address PCI DSS requirements incrementally on top of the already-built security foundation.
Frequently Asked Questions
Does SOC 2 cover PCI DSS requirements?
Can I use Stripe and avoid PCI DSS entirely?
What is the penalty for PCI DSS non-compliance?
Is Razorpay PCI DSS certified?
How long does PCI DSS certification take?
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